New air quality regulations focused on the oil and gas industry have challenged affected facilities to comply with the rigid regulatory framework of the Clean Air Act (CAA). Simply put, the CAA was not wired to address operations over wide geographical areas, ever-changing equipment, variable throughputs, and varied gas or oil compositions. Nonetheless, oil and gas operators must comply.
One particular challenge is found in upstream operations where individual sources are often small, and were historically believed to be below most air quality authorization or permitting thresholds. From a federal level, EPA has identified the exploration and production segment as an ongoing target for its National Enforcement Initiative for both the past and the next three years. State and local agencies are also focusing more than ever on Volatile Organic Compound (VOC), methane, and Hazardous Air Pollutant (HAP) air emission sources as they relate to the upstream and midstream oil and natural gas segment - and they are taking action. The Texas Commission on Environmental Quality (TCEQ), for example, recently performed a helicopter flyover of production sites in southwest Texas with a FLIR camera to evaluate VOC emissions. The North Dakota Department of Environmental Quality (DEQ) recently issued an industry-wide consent decree for facilities that may have under-estimated VOC emissions from storage vessels. The state of Colorado recently passed a suite of sweeping requirements that apply to all hydrocarbon emissions from production sites – not just VOC. Wyoming and Ohio have since followed suit to regulate all hydrocarbon emissions. And, the New Mexico Environment Department (NMED) has been providing oil and gas operators with copies of its current Civil Penalty Policy to encourage operators to step forward with their issues, and address compliance issues quickly.
Consider conducting a review of your air quality compliance. Click here for Trinity's recommendations on how to move forward, or contact Christine Chambers in Trinity's Dallas headquarters at (972) 661-8100 for more information.